Elizabeth Erickson Elizabeth Erickson

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  Elizabeth Erickson provides legal counsel on complex civil tax controversies, including tax litigation and transfer pricing matters. She has extensive experience in resolving domestic and international tax matters at all stages of dispute, including Internal Revenue Service examinations, administrative appeals, and litigation in the US Tax Court and district courts. She has advocated for clients before the Internal Revenue Service National Office, negotiated Advance Pricing Agreements with the Internal Revenue Service and other tax authorities, and resolved disputes through the Competent Authority process. Read Elizabeth Erickson's full bio.

New Proposed Regulations Limit Use of Non-Government Attorneys

By and on Mar 29, 2018
Posted In IRS Audits, IRS Guidance, Uncategorized

On March 28, 2018, the Treasury Department and Internal Revenue Service (IRS) published Proposed Regulation § 301.7601-1(b)(3)(i) and (ii) which permits the IRS to hire outside specialists to assist in determining the correctness of a taxpayer’s tax liability. The Proposed Regulation also contains an exception specifically prohibiting the IRS from hiring outside attorneys to review...

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Multilateral-APA-Like Program to Create International Tax Certainty for Pilot Participants

By and on Feb 5, 2018
Posted In Transfer Pricing Resource, Uncategorized

On January 23, 2018, the International Compliance Assurance Programme (ICAP) was launched at an orientation event in Washington, DC. The ICAP pilot is a voluntary program in which the participants will use country-by-country reporting and other information to establish multilateral agreements in order to establish early tax certainty and assurance. The ICAP handbook can be...

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Senior Tax Court Judge Robert A. Wherry, Jr. Retires

By and on Jan 8, 2018
Posted In Court Procedure Matters, Trial Courts, Uncategorized

On January 3, 2018, Chief Judge Marvel of the US Tax Court (Tax Court) announced that Senior Judge Robert A. Wherry, Jr. fully retired as of January 1, 2018, and would no longer be recalled for judicial service. Judge Wherry was appointed on April 23, 2003, by President George W. Bush. In 2014, Judge Wherry...

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To Agree or Not to Agree, That Is the Question

By and on May 17, 2017
Posted In IRS Appeals, IRS Audits, Uncategorized

The last few years have seen significant changes in audit procedures employed by the Internal Revenue Service (IRS). These changes range from the new Information Document Request (IDR) procedures to substantial changes at the IRS Appeals level. This post focuses on the IRS’s attempt to develop an agreed set of facts before a case is...

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ABA Section of Taxation Response to Recent Changes to IRS Appeals

By , and on May 10, 2017
Posted In IRS Appeals, Uncategorized

We have covered on several occasions the changes in the past year to the IRS Appeals process. See here, here, here, here and here. The reactions from taxpayers and practitioners to the recent changes has, for the most part, been negative. On May 9, 2017, the American Bar Association Section of Taxation provided comments to the...

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Giving Back – Providing Pro Bono Tax Assistance

By , , and on Feb 23, 2017
Posted In Trial Courts, Uncategorized

Here at McDermott, we value giving back to the community through pro bono efforts.  In particular, we provide substantial assistance in pro bono tax cases to low-income individuals through our relationships with low-income taxpayer clinics throughout the country.  Over the years, we have settled dozens of cases for low-income taxpayers in docketed tax cases and...

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Run for Cover—IRS Unveils Initial “Campaigns” for LB&I Audits

By , , and on Feb 1, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized

They’re here!  On January 31, 2017, the Internal Revenue Service (IRS) Large Business & International (LB&I) division released its much-anticipated announcement related to the identification and selection of campaigns.  The initial list identifies 13 compliance issues that LB&I is focused on and lists the specific practice area involved and the lead executive for each campaign. ...

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What to Expect During a Change of Administration

By , , , and on Jan 25, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Uncategorized

With the inauguration of President Trump, and the accompanying change of administration, the American people have been promised great change in all areas of the federal government. One question we at McDermott have been frequently asked since the election is: what should a taxpayer expect from the Internal Revenue Service (IRS) and the Department of...

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National Taxpayer Advocate Releases 2016 Annual Report to Congress

By on Jan 19, 2017
Posted In IRS Guidance, Uncategorized

On January 10, 2017, the National Taxpayer Advocate Nina E. Olson released her 2016 Annual Report to Congress. According to the Taxpayer Advocate Service (TAS), the report was delivered to Congress with no prior review by the Internal Revenue Service (IRS) Commissioner, the Secretary of the Treasury or the Office of Management and Budget.  The...

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IRS Identifies Certain 831(b) Captives As “Transactions Of Interest”

By and on Nov 11, 2016
Posted In IRS Guidance, Uncategorized

In Notice 2016-66, the Treasury Department and the Internal Revenue Service (IRS) identified a particular § 831(b) “micro-captive” transaction as a “transaction of interest” for purposes of § 1.6011-4(b)(6) of the Regulations and §§ 6111 and 6112 of the Internal Revenue Code. The notice also alerts persons involved in such transactions to certain responsibilities and...

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